Is the EU now gaming its climate targets?

The European Commission is once again delaying its proposal for the European Climate Law amendment to set a 2040 climate target.

Behind the missed deadlines lies a more concerning trend: an apparent willingness, by parts of the commission, some member states and parliamentarians, to water down the very target that should position the EU as a global climate leader.

As new options are reportedly being considered to make the 90 percent net-emissions reduction target more ‘flexible’, it is important to say plainly: these are not pragmatic tweaks. They are dangerous shortcuts.

The 90 percent net-reduction by 2040, announced in the commission’s February 2024 communication and enshrined in the Clean Industrial Deal and the Competitiveness Compass, was already a middle-ground.

While politically significant, it sits at the bottom end of the 90-95 percent reduction range recommended by both the European Scientific Advisory Board on Climate Change (ESABCC) and the commission’s own impact assessment. These assessments also indicate that the higher the ambition, the fairer the EU contribution and the greater the benefits for the Union, not only for the climate, but for health, the economy, and resilience.

Critically, it also falls short in equity considerations.

For example, the UN secretary general highlighted the need for so-called developed countries to already reach climate neutrality (net zero) by 2040 (a demand backed by CAN Europe), and significantly earlier than poorer countries who have contributed less to historic pollution.

Let’s examine the shortcut four options that are reportedly under consideration:

1. Backloading emission cuts

One option being discussed would slow emissions reductions in the early 2030s and concentrate action later in the decade.

This not only delays progress, it increases overall emissions over time, especially at a time when early action is more effective and cheaper.

A backloaded trajectory would also weaken the Union’s next Nationally Determined Contribution (NDC) which must have a 2035 reduction target as its centrepiece, expected ahead of COP30 in Brazil. At a time when global climate diplomacy is faltering, the EU must strengthen, not erode, its leadership.

2. Buying credits abroad: exporting responsibility, importing greenwashing

Allowing international carbon credits to count toward the 90 percent target would be at odds with the European Climate Law’s current approach, which, for good reasons, is grounded in domestic emissions reductions.

It contradicts the ESABCC's advice and introduces serious risks to environmental integrity, with evidence of greenwashing and weak accountability plaguing many carbon credit schemes.

Worse still, some member states seem to be eyeing the possibility of counting these purchases as climate finance, a move that would amount to double counting, at the expense of developing countries that need genuine support.

Moreover, it would channel some of the investments elsewhere and potentially undermine the affordability of domestic climate solutions due to lower carbon price levels from cheap credits.

3. Inflating the role of carbon removals

The commission is also considering increasing the share of carbon removals in the net target. These include both natural methods, like land-based sequestration, and technological options, such as carbon capture and storage.

Removals cannot be treated as equivalent to real emissions reductions though.

Natural sinks are temporary and vulnerable to disturbances. Technological removals are still unproven at scale and often face sustainability constraints. Using removals to mask continued emissions delays the structural transformation required across the economy.

4. Shifting responsibility between sectors

Another option considered is to introduce more flexibility for member states to meet sectoral targets, allowing underperformance in one area to be offset by over-performance in another.

While some flexibility already exists in the EU’s climate framework, expanding it further would weaken incentives for progress in key sectors like transport, buildings, or agriculture. This undermines the core logic of economy-wide decarbonisation and delays action where it is needed most.

Watering down the 2040 target does not only threaten the EU’s environmental credibility, it undermines its long-term competitiveness.

Research conducted by CAN Europe shows that more ambitious climate action would bring significant co-benefits: a stronger economy, cleaner air, improved public health, and millions of new jobs across the Union.

This message is also echoed by the business community — who underline the importance of clear, science-based targets to drive investment, innovation, and economic resilience.

The EU cannot lead globally by outsourcing, delaying, or disguising its climate efforts.

A 2040 target riddled with loopholes may be easier to negotiate, but it will be harder to justify to citizens, businesses, and the international community. The time to act with clarity and resolve is now.

The EU must stick to the science, uphold its legal commitments, and reject options that trade ambition for accounting tricks. In the climate crisis, shortcuts are not solutions.